Curate Health (9012358) - Improvement action plan

The pharmacy does not keep clear records of the consultations it has with people to provide evidence of its prescribing decisions and support any follow up or ongoing monitoring. So it cannot demonstrate that each supply of medicine it makes is clinically appropriate.

1. Mandate that all prescribers document a clear reason for either approving or rejecting a prescription during every consultation, this includes for any dose escalations. This rationale must include clinical justifications based on the patient’s medical history, current medications, and submitted evidence.

2. Introduce a mandatory follow-up process for all high-risk medications, with records of patient progress and side effect management.

3. Conduct regular internal audits to ensure records meet legal and clinical standards.

The pharmacy does not fully manage the risks associated with supplying weight loss medicines to people remotely. It cannot show that it always gets enough, reliable information about a person before making a supply of medicine.

1. The pharmacy has implemented a new patient consultation form that captures patient information in a more detailed fashion. This enables it to build up a comprehensive picture of the individual, from full body images, through to understanding when their last injection was taken, through to gaining evidence on any medication they are currently on.

2. The pharmacy has put in place guidelines that if evidence submitted does not meet its prescribing guidelines to ‘justify and explain’, a prescriber must request evidence from a customer, whether that be photo, video or video consultation.

3. Implement mandatory ID verification and medical evidence submission (e.g., NHS app or copy of repeat prescription) for high-risk medications.

4. Conduct independent regular audits of consultation records to ensure data sufficiency before prescribing.

5. The pharmacy has implemented an automatic flagging system that pulls through all flagged patient information e.g. medical conditions/medication, this is displayed as an alert to the prescribers.

The pharmacy cannot demonstrate that it seeks sufficient information regarding people's body mass index (BMI) to ensure the medicines it supplies are clinically appropriate.

1. Require all patients to submit recent weight, height, full body images and images of scale readings or evidence of weight/bmi from another HCP or body measurement monitors

2. Train prescribers to assess BMI data alongside other health metrics to ensure clinically appropriate decisions.

3. Include BMI calculations in the consultation record to demonstrate compliance during audits.

4. Request video consultations or patient recorded videos to verify patient BMI

5. Request dated images to be provided within the first order with Curate